Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C
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Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20544 In the Matter of Skype Communication’s Petition to Apply RM – 11361 Carterfone Attachment Regulations to the Wireless Industry DECLARATION IN SUPPORT OF COMMENTS OF AT&T INC. OPPOSING SKYPE COMMUNICATIONS’ PETITION TO APPLY CARTERFONE ATTACHMENT REGULATIONS TO THE WIRELESS INDUSTRY 1. My name is Kelly Williams. My business address is 5565 Glenridge Connector; Atlanta, Georgia. I am an Executive Director in the Technical organization. In this position, I am responsible for planning and developing strategy for our core network architecture. I am responsible for paragraphs 8, 9, 10, 11, 12, 13, 43, 46, 47, 48, 49, and 50 of this declaration. 2. My name is Michelle Mindala. My business address is 5565 Glenridge Connector; Atlanta, Georgia. I am the Executive Director - Product Management, Devices & Accessories. In this position, I am responsible for the consumer-focused device product portfolio, program management, SIM cards & the SIM lock policy, and AT&T Mobility’s accessory business. I am responsible for paragraphs 14, 15, 16, 17, 32, and 33 of this declaration. 3. My name is Cameron Coursey. My business address is 892 Woods Mill Road; Ballwin, Missouri 63011. I am an Executive Director in the Technical organization. In this position, I am responsible for the certification and testing of devices. I am responsible for paragraphs 18, 19, 20, 21, 22, 23, 24, 34, 35, and 36 of this declaration. 4. My name is Ed Lambert. My business address is 16771 Northeast 72nd Way; Redmond, Washington. I am a Director in the Technical organization. In this position, I am responsible for the development of management of the certification process for data services and applications. I am responsible for paragraphs 37, 38, 39, 40, 41, and 42 of this declaration. 5. My name is Jim Ryan. My business address is 5565 Glenridge Connector; Atlanta, Georgia. I am a Vice President in the Marketing organization. In this position, I am responsible for Consumer Data Products and Services. I am responsible for paragraphs 44, 45, 46, 47, 48, and 49 of this declaration. 6. My name is Cathy Quaciari. My business address is 16771 Northeast 72nd Way; Redmond, Washington. I am a Director in the Business Marketing Group. In this position, I am responsible for developing data products and offerings for business customers. I am responsible for paragraphs 25-31 of this declaration. 7. The purpose of this declaration is to address certain claims made in Skype’s petition for rulemaking relating to the wireless handset, application, and data usage policies of AT&T Mobility LLC (“AT&T”), formerly known as Cingular Wireless LLC. This declaration first provides an overview of AT&T’s wireless network and services. It then describes AT&T’s handset certification policies and, in connection with that discussion, corrects certain misstatements in Skype’s petition relating to functionalities that are (and are not) enabled on certain specific handsets sold by AT&T. The declaration then discusses AT&T’s application certification policies, and it concludes by addressing usage policies adopted by AT&T. AT&T’s Wireless Network 8. AT&T’s wireless network – the ALLOVER™ network – has the largest digital voice and data coverage in the United States. Over that network, AT&T offers an array of 2 wireless voice and data services to more than 61 million customers across the nation. AT&T’s network provides subscribers with a nationwide Global System for Mobile communication (“GSM”) and General Packet Radio Service (“GPRS”) footprint across 100% of AT&T’s service area, covering the top 100 U.S. markets and more than 273 million people. AT&T’s wireless network also includes the nation’s largest national high-speed wireless data network with Enhanced Datarate for GSM Evolution (“EDGE”) technology, which is available in 13,000 cities and towns and along almost 40,000 miles of U.S. highways. 9. In addition, AT&T has rolled out its third-generation (“3G”) BroadbandConnect service, which uses Universal Mobile Telecommunications System/High Speed Downlink Packet Access (“UMTS/HSDPA”) technology, a worldwide standard for wide-area wireless data communication based on W-CDMA and compatible with GSM/Edge. AT&T was the first wireless carrier in the world to deploy widely HSDPA technology. UMTS/HSDPA, in turn, provides high levels of spectral efficiency for voice and data, simultaneous voice and data capability, and can support high-bandwidth data applications. 10. AT&T’s 3G services provide average mobile data connections between 400 and 700 kbps, with bursts up to more than one megabit per second, and are available in most major U.S. markets. AT&T’s 3G services use the only 3G technology natively supporting simultaneous circuit switched voice and packet switched data communications. 11. In order to provide high-quality, reliable, cost-effective wireless services over its network, AT&T must address various challenges posed by wireless communications. To begin with, all wireless communications on our networks – whether voice or data – take place within assigned (licensed) wireless spectrum bands. Because each communication must occur on specific frequencies within those bands, there are absolute limits on the uses any wireless 3 network can support in any particular geographic area. Although advances in digital technologies allow carriers to increase the efficiency of wireless networks and to provide capacity for simultaneous uses, there are undeniable physical constraints on the wireless spectrum. 12. A related challenge is the shared and finite nature of the wireless spectrum. Because AT&T has available to it only a finite amount of wireless spectrum to serve any particular geographic area, subscribers that make inefficient uses of the network affect the ability of AT&T to provide quality and reliable services to other subscribers in that same area. Various uses by subscribers may demand substantially different amounts of the available bandwidth and thereby have different effects on AT&T’s wireless network. A text-oriented message, for example, can be effectively transmitted using only 8-32 kbps, whereas a streaming video may require 100-500 kbps or more. 13. In addition to those challenges, AT&T and its partners in the wireless industry must figure out ways to deliver wireless voice and wireless broadband services and content that work well using wireless transmission, that are attractive on small handset screens, that economize on limited battery life, and that do not require the use of wireless handsets that will be priced out of the market’s willingness to pay. AT&T is continually striving to provide consumers with new and innovative wireless services and content that are compatible with the physical and economic limits of its network. AT&T’s Handset Policies 14. Wireless handsets are an integral component of AT&T’s wireless network. AT&T has adopted handset policies designed to encourage wireless subscribership, to ensure 4 device interoperability with the network, and to ensure the efficient and reliable use of its wireless network. Two relevant policies relate to subsidization and certification. 15. Subsidization and locking. Wireless handsets, especially those capable of providing broadband services, are expensive. If subscribers faced the full costs of those handsets, then wireless subscribership and penetration would suffer. To encourage subscribership, penetration, and use of new and more efficient handsets, AT&T, by subsidizing the price of handsets, absorbs a significant amount of the cost of a handset in return for a service commitment from the subscriber. As such, AT&T wireless handsets are “locked” – meaning that they cannot be used with a non-AT&T SIM card (it is important to note that locking does not prevent the handset, when used with an AT&T SIM, from working or roaming on other networks with whom AT&T has roaming agreements; it just prevents the device from being used with a non-AT&T SIM). The handset is locked for the duration of the service commitment or until the consumer’s contractual obligation is fulfilled. After such obligation is fulfilled, however, AT&T will allow a customer to unlock a handset upon the customer’s request if the handset supplier has permitted us to do so and has provided AT&T with this capability. 16. By enabling AT&T to recover the substantial subsidies incurred in the sale of handsets over the service-commitment period, locking encourages AT&T to provide those subsidies. Absent locking, it would be cost-prohibitive for AT&T to offer substantial handset subsidies. 17. AT&T does allow handsets to be purchased without service plans (and therefore without subsidies) and will unlock those handsets upon a customer’s request if the handset supplier has permitted us to do so and has provided AT&T with this capability. Consumers therefore have a basic choice of purchasing a subsidized handset with a service commitment and 5 having their handset locked or purchasing an unsubsidized handset and having AT&T immediately unlock the handset. The overwhelming majority of consumers elect the subsidy that comes with a service commitment and a locked handset. 18. Handset certification. Handset certification is a process through which AT&T strives to create an integrated end-to-end experience for consumers. AT&T’s business goal is to create a complete end-to-end service such that subscribers know that the services, features, and equipment that they use in connection with AT&T’s network will be of the highest quality. 19. AT&T’s certification policy is one way that AT&T ensures that handsets are compatible with and optimized for use on its network. The aim of certification is to maintain interoperability and integration between the wireless device and the network, thereby providing the best quality service for the subscriber without jeopardizing the service of others.